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1991 (8) TMI 135 - AT - Income TaxExtract: ....... deliberate omission it is not for us to state. Suffice it to say that strict construction should be placed on the expressions used in a penal section vide Sri Radhakrishna Trading Co. v. CIT 1954 26 ITR 666 (Mad.) and CA. Abraham v. ITO 1961 41 ITR 425 (SC). 11. In the result, the appeals are allowed and the order of the CIT (Appeals) is cancelled
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